CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-1

CHAPTER 8: FINAL SECTION 4(f) EVALUATION

8.1 INTRODUCTION 

This final Section 4(f) evaluation is an update and refinement of the Draft Section 4(f) Evaluation 

that was circulated for public comment as part of the Draft EIS/EIR from October 4 to December 

20, 2002. Three public hearings and an open house were held on November 12, November 13 

(including the open house), and November 26, and public comments were taken at all four meetings. 

 The public comment period on the Draft EIS/EIR ended on December 20, 2002. 

A Locally Preferred Alternative has been identified after consideration of the information presented 

in the Draft EIS/EIR, public and agency input from the circulation of the Draft EIS/EIR, meetings 

among affected stakeholders, community meetings and workshops, and the public hearings. The 

Locally Preferred Alternative consists of the following project components: the Transbay Terminal 

West Ramp Alternative with its associated bus ramps, circulation, and off-site storage; the Caltrain 

Downtown Extension with the “stacked drift” tunneling option for the segment between Townsend 

Street and Folsom Street and the Second –to-Main Alternative alignment north of there; and the 

Transbay Redevelopment Plan Area “full build” development alternative. 

This discussion complies with the federal requirements found in 49 USC, Section 303, commonly 

referred to as Section 4(f). These requirements pertain to all actions or projects undertaken by 

agencies within the U.S. Department of Transportation, including the Federal Transit Administration 

(FTA). The essence of Section 4(f) requirements is that special efforts are to be made to protect 

public park and recreation lands, wildlife and waterfowl refuges, and historic sites. The law states 

that the Secretary of Transportation shall approve a project which requires the use of land from a 

significant publicly-owned park, recreation area, wildlife or waterfowl refuge, or historic site of 

significance only if (1) there is no prudent and feasible alternative to the use of that land and (2) the 

project includes all possible planning to minimize harm to the resource being affected by that use. 

As defined under Section 4(f), use occurs when protected land is permanently acquired for a 

transportation facility, when a temporary use is considered adverse, or when there is "constructive 

use" of the resource. Constructive use occurs when indirect impacts are so severe that the activities, 

features, or attributes that qualify the resource for protection are substantially impaired. 

The Locally Preferred Alternative will use Section 4(f) resources through direct acquisition and 

temporary occupancy, but it does not involve any constructive use. Pursuant to DOT Rules and 

Regulations, Part 771 Section 771.135 (p) (5) (I), constructive use of an historic property does not 

occur when “compliance with the requirements of Section 106 of the National Historic Preservation 

Act and 36 CFR Part 800 for proximity impacts of the proposed action . . . results in an agreement of 

... no adverse effect.’” Because the proximity impacts of the project on historic properties (other 

than those that would be directly used) have been determined to result in “no adverse effect” under 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-2 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

Section 106 regulation, these proximity impacts would not result in a constructive use of the historic 

resources in question. 

Section 4(f) applies to the present project because both Transbay Terminal alternatives would 

require the use of land from the site of the Transbay Terminal, demolition and removal of the 

Transbay Terminal building, and demolition and removal of the terminal loop ramp structures that 

connect the terminal to the San Francisco-Oakland Bay Bridge. The terminal loop ramp structures 

and the terminal are contributing elements of the Bay Bridge, which is listed on the National 

Register of Historic Places (NRHP). 

In addition, either Caltrain Downtown Extension Alternative using cut-and-cover construction 

would require demolition and removal of 13 other buildings that are contributors to a historic district 

that is, by consensus of the Section 106 consulting parties, eligible for the NRHP. Either Caltrain 

Downtown Extension Alternative constructed using the tunneling option for the segment between 

Townsend Street and Folsom Street (which option is part of the locally preferred alternative) would 

require demolition and removal of three such contributory buildings. Ten of the 13 buildings are 

contributors to the Rincon Point / South Beach Industrial Warehouse Historic District, which was 

identified as appearing eligible for the NRHP in 1983. The other three buildings are contributors to 

the Second and Howard Streets Historic District, which was determined eligible for the NRHP in 

1999. 

Pursuant to DOT Rules and Regulations Part 771.135 (g) (2), Section 4(f) does not apply to 

archaeological sites where the FTA, after consultation with the State Historic Preservation Officer 

(SHPO) and the Advisory Council on Historic Preservation (ACHP), determines that the 

archaeological resource is important chiefly because of what can be learned by data recovery and has 

minimal value for preservation in place, and data recovery is undertaken. On the basis of this 

qualification, Section 4(f) does not apply to any of the archaeological resources identified in the 

project area. The Section 106 Historic Preservation Agreement in Appendix G details the actions 

that will be taken to recover the archaeological data present in the identified resources. 

Furthermore, the Agreement establishes procedures that will be followed during construction if an 

unanticipated discovery of archaeological resources occurs. 

8.2 PROJECT PURPOSE AND NEED 

The Transbay Joint Powers Authority, City and County of San Francisco, Peninsula Corridor Joint 

Powers Board (JPB), and San Francisco Redevelopment Agency propose to construct a new multimodal Transbay Terminal on the site of the present Transbay Terminal, extend Caltrain commuter 

rail service from its present northern terminus at Fourth and Townsend Streets in San Francisco to an 

underground terminus in the basement of a new Transbay Terminal, and establish a redevelopment 

area plan and related development projects, including transit-oriented development on publiclyowned land in the vicinity of the new terminal. The primary purposes of the project are to improve 

public access to bus and rail services, modernize the Transbay Terminal and improve its service, 

reduce non-transit vehicle usage, and revitalize the Transbay Terminal area. The project will also 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-3

address a number of related needs. It will improve Caltrain commute service by providing direct 

access to downtown San Francisco and enhance connectivity between Caltrain and other major 

transit systems. It will accommodate future intercity or high-speed rail services. The project is also 

expected to serve future travel demand in the San Jose - San Francisco corridor and alleviate traffic 

congestion on US Highway 101 and I-280 between San Jose and San Francisco as well as other 

routes; improve regional air quality; enhance accessibility to employment, retail and entertainment 

opportunities; and support local economic and land use development goals. More detailed 

discussion of the project purpose and need is provided in Chapter 1, Purpose of and Need for the 

Project.

8.3 PROJECT DESCRIPTION 

The proposed project has three major components, as follows: 

• A new, multi-modal Transbay Terminal on the site of the present Transbay Terminal; 

• Extension of Caltrain commuter rail service from its current San Francisco terminus at Fourth 

and Townsend Streets to a new underground terminus underneath the proposed new Transbay 

Terminal; and 

• Establishment of a Redevelopment Area Plan with related development projects, including 

transit-oriented development on publicly owned land in the vicinity of the new multi-modal 

Transbay Terminal.

Of various alternatives considered, two Transbay Terminal Alternatives, two Caltrain Downtown 

Extension Alternatives, and two Redevelopment Alternatives were carried forward into conceptual 

engineering and environmental studies. Both of the Caltrain Downtown Extension Alternatives 

included design options. A brief description of these alternatives and options is provided in the 

following paragraphs; Chapter 2, Description of the Project Alternatives, describes these alternatives 

and options in detail. 

8.3.1 TRANSBAY TERMINAL ALTERNATIVES

Two alternatives were studied for a new Transbay Terminal. Under either alternative, a new multimodal terminal would be located at the site of the existing Transbay Terminal. Bus ramps would 

connect directly from the new terminal to the San Francisco-Oakland Bay Bridge, while a rail 

facility in the basement of the new terminal would provide space for the terminus of the Caltrain 

Downtown extension and for potential future East Bay commuter rail and California’s high-speed 

intercity rail. The new terminal would provide facilities for AC Transit, Golden Gate Transit, 

Greyhound, and Muni buses and trolley coaches, paratransit, and for Greyhound Package Express 

and private taxi services. It would also include space for retail and cultural uses. It would 

incorporate sustainable design features to conserve energy and water resources. 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-4 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

8.3.1.1 Transbay Terminal West Ramp Alternative (Included in Locally Preferred 

Alternative) 

The Transbay Terminal West Ramp Alternative proposes to construct a terminal one block (165 feet) 

wide by three blocks (1,300 feet) long on the site of the existing Transbay Terminal, requiring 

demolition of the existing terminal and its loop ramp. The new Terminal would include six levels, 

with four levels above ground and two below, comprising an underground train level with a direct 

connection to the train platforms from the Transbay Terminal; an underground train mezzanine; a 

street level for bus services; an above-ground pedestrian concourse including 150,000 to 225,000 

square feet of retail, entertainment, conference, educational, and cultural uses; and two aboveground bus decks. Elevators and escalators would provide for pedestrian circulation between levels. 

This Transbay Terminal alternative has been identified for the terminal component of the Locally 

Preferred Alternative. 

Under this alternative, new direct bus ramps between the terminal and the Bay Bridge would be 

constructed on the west side of the terminal building in generally the same location as the existing 

ramps paralleling Essex Street. The existing loop ramp would be demolished and would not be 

rebuilt. Midday bus storage would be provided off-site under the west Bay Bridge approaches 

between Second and Fourth streets. Please see Section 2.2.1.1, Transbay Terminal West Ramp 

Alternative, for a detailed description of this alternative. 

8.3.1.2 Transbay Terminal Loop Ramp Alternative 

The Transbay Terminal Loop Ramp Alternative proposes to construct a terminal one block (165 

feet) wide and three blocks (1,300 feet) long on the site of the existing Transbay Terminal, requiring 

demolition of the existing terminal and its loop ramp. It would include five levels: an underground 

train level; an underground train mezzanine; a street level for bus services; an above-ground 

pedestrian concourse including entertainment, conference, educational, and cultural uses; and an 

above-ground bus level. Vertical pedestrian circulation would be provided as in the West Ramp 

Alternative. 

The Loop Ramp Alternative would reconstruct both the west and east bus ramp structures, providing 

for a full one-way loop of bus circulation through the new Transbay Terminal, with direct 

connections to the Bay Bridge on both the east and west sides of the terminal building. The Loop 

Ramp Alternative would allow for some midday bus storage on the ramps, with the remaining 

storage off-site under the west Bay Bridge approaches. Please see Section 2.2.1.2, Transbay 

Terminal Loop Ramp Alternative, for a more detailed description of this alternative. 

8.3.2 CALTRAIN DOWNTOWN EXTENSION ALTERNATIVES

The Caltrain Downtown Extension component of the project consists of an underground extension of 

Caltrain from its present San Francisco terminus at Fourth and Townsend Streets to a new 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-5

underground terminal at the site of the present Transbay Terminal at First and Mission Streets. The 

extension would consist of two to four tracks branching to several additional tracks into the 

basement of the proposed new Transbay Terminal. The extension would include new mainline 

tracks as they pass the Caltrain Fourth and Townsend storage yard, with a new subsurface 

station/platform near Fourth Street adjoining Townsend Street. 

The extension alignment would enter a portal south of Townsend near Fifth Street, pass the new 

subsurface Fourth and Townsend platform, and continue eastward below grade under Townsend 

Street in a cut-and-cover tunnel configuration. It would then curve northward just east of Third 

Street in a cut-and-cover configuration to Second and Brannan Streets. The alignment would then 

continue in a cut-and-cover configuration under Second Street for about 2,055 feet. 

8.3.2.1 Caltrain Extension Tunneling Option (Included in Locally Preferred Alternative)

Use of tunneling rather than cut-and-cover is an option for the portion of the underground Caltrain 

Extension between Townsend Street and Folsom Street. A highly specialized tunneling technique 

known as the “stacked drift” approach is suitable to the fractured rock geology of this portion of the 

alignment. It involves very little risk of collapse and was evaluated specifically as an alternative to 

preserve many of the buildings under which the tunnel alignment would pass. Please see 

Sections 2.2.2.3 and 5.20 for more detail on this tunneling option, which has been identified as the 

preferred option for tunneling this Caltrain Downtown Extension segment in the Locally Preferred 

Alternative. 

Two Caltrain Extension alignment alternatives are under consideration from Howard Street 

northward, both of which would be in a cut-and-cover configuration, as described in the following 

sections. 

8.3.2.2 Second-to-Main Caltrain Extension Alternative (Included in Locally Preferred 

Alternative) 

As the Second-to-Main Caltrain Extension Alternative approaches Howard Street along Second 

Street, it would curve 90 degrees northeasterly, into the basement of the proposed new Transbay 

Terminal. It would have six tracks and three platforms within the Terminal building and would 

include approximately 2,000 feet of additional tracks in a cut-and-cover configuration from the east 

end of the new Terminal, curving 90 degrees south to Main Street, and continuing underneath Main 

Street to south of Folsom Street. This track could be used for temporary train storage and could be 

extended for a San Francisco-to-Oakland cross-bay alignment as a separate project. This alternative 

would include an option for an 800-foot-long pedestrian connection underneath Fremont Street to 

the BART Embarcadero Station. The Second-to-Main Alternative has been identified as the Caltrain 

Extension component of the Locally Preferred Alternative. 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-6 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

8.3.2.3 Second-to-Mission Caltrain Extension Alternative 

The Second-to-Mission Alternative would follow the same alignment as the Second-to-Main 

Alternative up Second Street to about Howard Street. As the alignment approaches Howard Street, 

rather than entering the terminal from the west and parallel to the axis of the terminal, it would curve 

northeasterly at about Tehama Street, cutting diagonally under what is known as the “hump” area in 

front of the present Transbay Terminal and would exit out Mission Street towards The Embarcadero. 

Two tracks would continue under Mission Street in a cut-and-cover configuration; these could be 

used for temporary train storage and could be extended for a San Francisco-to-Oakland cross-bay 

alignment as a separate project. 

Please see Section 2.2.2, Caltrain Downtown Extension Alternative, for a more detailed description 

of this project component. 

8.3.3 REDEVELOPMENT ALTERNATIVES

The third component of the project consists of establishment of a Redevelopment Plan Area and 

related development projects, including transit-oriented development on publicly owned land in the 

vicinity of the proposed new multi-modal Transbay Terminal. There are two alternatives to this 

component: a “full build” development scenario and a “reduced scope” development scenario. 

8.3.3.1 Full Build Development Scenario (Included in Locally Preferred Alternative) 

The Full Build Alternative includes about 7.6 million square feet (sq. ft.) of new residential / office / 

retail / hotel development, including approximately 5.6 million sq. ft. (74 percent of the total 

development) of residential development (4,700 residential units including affordable housing); 

1.2 million sq. ft. of office development; 475,000 sq. ft. of hotel development; and 355,000 sq. ft. of 

retail development. This scenario has been identified for the redevelopment component of the 

Locally Preferred Alternative. 

8.3.3.2 Reduced Scope Development Scenario 

The Reduced Scope Alternative assumes a lesser amount of commercial and retail development and 

is weighted more toward housing. It assumes approximately 5.4 million sq. ft. of residential / office 

/ retail / hotel development, including 4.7 million sq. ft. (87 percent of the total development) of 

residential development (3,900 dwelling units); 350,000 sq. ft. of hotel development; and 200,000 

sq. ft. each of office and retail development. 

8.3.4 THE NO-PROJECT ALTERNATIVE

The No-Project Alternative represents existing and committed (that is, funded) transportation 

services and facilities in the project corridor. The No-Project Alternative consists of existing 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-7

Caltrain service plus funded improvements and other committed bus, rail, and roadway 

improvements to the 2020 horizon year and a BART extension to the San Francisco International 

Airport. 

8.3.5 ALTERNATIVES CONSIDERED AND WITHDRAWN

Other alternatives considered for the Transbay Terminal and Caltrain Extension project elements 

were withdrawn from further study because they would not accomplish the purpose and need for the 

project; would severely constrain railroad or bus operations; would constrain pedestrian circulation; 

would have severe community impacts; had extemely poor constructability; or would have involved 

extraordinary costs or substantial risk. These alternatives and the reasons why they were withdrawn 

from further consideration are described in Section 2.3, Alternatives Considered and Withdrawn. 

None of these alternatives offered a feasible and prudent alternative for avoiding the use of Section 

4(f)-protected resources. 

8.4 DESCRIPTION OF SECTION 4(F) PROPERTIES 

Both Transbay Terminal alternatives and both Caltrain Downtown Extension alternatives would 

require the use of land from the Transbay Terminal property and demolition and removal of the 

Transbay Terminal building, which is eligible for the NRHP and is a contributing element to the 

San Francisco-Oakland Bay Bridge, which is listed on the NRHP. Both TransbayTerminal 

alternatives would also require demolition and removal of the existing terminal loop ramp 

structures, which are also contributing elements to the Bay Bridge. 

Cut-and-cover tunnel construction for either Caltrain Downtown Extension alternative would 

require the use of land from and demolition of 13 buildings that are either individually eligible or 

eligible for listing in the NRHP as contributory elements to a district that is or appears eligible for 

listing. These demolitions would result in the use of individual buildings in the district. 

The Tunnel Option for the Caltrain Downtown Extension alternatives would require the use of land 

from and demolition of three buildings that are eligible for listing in the NRHP as contributors to a 

district that is eligible for listing. Demolition of these three buildings would also result in the use of 

individual buildings in the district. 

Both alternatives would also require a construction easement through the corner of a fourteenth 

property that is a contributor to an eligible district. This building would not be demolished, and the 

construction easement would not result in its use under Section 4(f). 

The following sections discuss each of these 4(f) properties. Maps showing their locations are 

provided in Figures 8.4-1 and 8.4.2 The Redevelopment Area component would not require the use 

of Section 4(f) property.
CHAPTER 8: FINAL 4(f) EVALUATION 

8-8 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

8.4.1 THE TRANSBAY TERMINAL

The Transbay Terminal at 425 Mission Street occupies land extending from Mission Street on the 

north to Natoma Street on the south; the terminal building crosses Fremont Street on the east and 

First Street on the west (Figure 8.4-1 #1). It was designed by Timothy Pfleuger, Arthur Brown, Jr., 

and John J. Donovan, consulting architects. Built in 1939, the Transbay Terminal was the 

“functional successor to the Ferry Building. When electric trains began arriving over the Bay 

Bridge, use of the Ferry Building dropped to almost nothing overnight, and the Transbay Terminal 

took over as the primary gateway to the city.” (Caltrans, 1983) The Terminal has been determined 

eligible for listing in the NRHP by consensus of the SHPO and a federal agency (FHWA) and is 

considered as a contributory element to the historic significance of the Bay Bridge. The present 

owner of the Transbay Terminal is Caltrans. Its current use is for commuter and inter- and intraregional bus transportation. 

8.4.2 THE TRANSBAY TERMINAL LOOP RAMP

The Transbay Terminal Loop Ramp (Figure 8.4-1 #2), which leads from the Bay Bridge approaches 

to the Transbay Terminal, would be demolished to construct the new Transbay Terminal component 

of the project. 

The Transbay Terminal loop ramp structure constitutes two of the six approach spans that remain 

from the original Bay Bridge project. The loop ramp and approach spans are contributing elements

of the Bay Bridge. Originally designed to carry trolley trains from the bridge to the terminal, the 

ramp’s tracks were removed when electrified trains gave way to buses in the late 1950s. The 

terminal loop ramp currently serves bus traffic exclusively and is used for midday storage of transit 

buses. 

8.4.3 THE SAN FRANCISCO – OAKLAND BAY BRIDGE 

The Bay Bridge (Figure 8.4-1 #3) is an eight and one-half mile long series of connecting structures 

carrying two levels of traffic between San Francisco and Oakland. Opened to service in 1936, in its 

original design, the bridge upper level carried two-way auto traffic while the lower level carried 

truck and trolley traffic. Structurally, the bridge is distinctive in its use of a variety of bridgebuilding technologies, the length of its 1,400-foot cantilever channel span on the east (Oakland) side, 

and the length of the two 2,320-foot suspension spans on the west (San Francisco) side. 
 CHAPTER 8: FI

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-9
CHAPTER 8: FINAL 4(f) EVALUATION 

8-10 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-11

The outstanding engineering feature is the center pier between the two suspension spans of the 

western half of the bridge. The tunnel connections between the east and west spans on Yerba Buena 

Island was the first double-decked highway tunnel in the United States. Notable individuals 

connected wth the project were Charles H. Purcell, Chief Engineer; Charles E. Andrew, Bridge 

Engineer; Glenn B. Woodruff, Design Engineer; and T. L. Pfleuger, Arthur Brown, Jr., and John J. 

Donovan, consulting architects. The Bay Bridge was evaluated by Caltrans in 1983 as meeting 

National Register eligibility criteria A, B, and C at the national level; it was determined eligible for 

listing in 1985. It was listed on the NRHP as a multi-component property on August 31, 2001. 

8.4.4 RINCON POINT / SOUTH BEACH HISTORIC WAREHOUSE-INDUSTRIAL DISTRICT

The Rincon Point / South Beach Historic Warehouse-Industrial District (Figure 8.4-2 #1) was 

identified and designated in the 1983 survey by Caltrans. It was developed beginning in the 1850s 

and 1860s, when landfill efforts and warehouse construction changed the physical appearance of the 

“point” and “beach” forever. This district contains the greatest concentration of architectural 

resources within the project vicinity. The district was identifed as appearing eligible for the NRHP in 

1983, based on research completed by Caltrans historians for the I-280 Transfer Concept Project, but 

it was never determined eligible by the SHPO. That research found that the district appeared eligible 

under all four National Register criteria. About 60 buildings within the district have been identified 

as contributing to the district’s significance. Approximately eight of these buildings date from before 

the 1906 San Francisco earthquake, with several from the mid-1800s. 

The Rincon Point / South Beach Historic Warehouse Industrial District has also been designated 

locally significant and is eligible for listing in the California Register of Historic Places. 

In 1985, the San Francisco Planning Department proposed the “South End Historic District,” and the 

San Francisco Planning Commission designated this district under its landmarks program in 

February 1990. The South End Historic District has nearly identical boundaries and is nearly the 

same size as the Rincon Point District identified by Caltrans. The National Register status of the 

properties within the district, whether recognized as part of the South End district or Rincon Point / 

South Beach district, is the same. Please see Section 4.16.6, Historic Architectural Resources, for 

more detailed descriptions of both the NRHP and City of San Francisco districts. 

8.4.5 SECOND AND HOWARD STREETS DISTRICT

The Second and Howard Streets District (Figure 8.4-1 #4) was determined eligible for the NRHP in 

1999. This small district consists of 19 contributing properties and three non-contributors (two 

heavily-altered buildings and a vacant lot) with addresses on Second, Howard, Natoma and 

Montgomery streets. The contributing buildings date from 1906 to 1912; the primary original uses of 

these buildings were wholesaling, light manufacturing, and printing. The area was built for services 

to the construction industry. The permit for the first building to be erected in the District was 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-12 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

approved on July 5, 1906, just two and a half months following the 1906 earthquake and fire. The 

Second and Howard Streets District is partially surrounded by a locally recognized district known as 

the “New Montgomery – Second Street Conservation District.” The San Francisco Planning 

Commission uses the conservation district designation to recognize parts of the city that have 

substantial concentrations of “special architectural and aesthetic importance.” Please see Section 

4.16.6, Historical Architectural Resources, for more detailed descriptions of both the NRHP and City 

of San Francisco districts. 

As many as eighteen historic buildings, including ten contributors to the Rincon Point / South Beach 

Industrial Warehouse District and seven contributors to the Second and Howard Streets District 

would be affected by the project. The Locally Preferred Alternative including the Tunnel Option for 

the segment of the Caltrain Extension Alternative between Townsend Street and Folsom Street would 

affect seven contributors to the Second and Howard Streets District. The Locally Preferred 

Alternative would also require a construction easement through the corner of another property (the 

eighteenth property previously mentioned) that is a contributor to the Rincon Point / South Beach 

Industrial Warehouse District. This building would not be demolished, and the construction 

easement would not result in use of the building under Section 4(f). The Transbay Terminal and 

ramps, which are contributors to the San Francisco-Oakland Bay Bridge, would be demolished and 

removed. Descriptions of each affected property are provided in Section 5.14, Historic and Cultural 

Resources.

Table 8.4-1 summarizes the impacts to the Section 4(f) properties that would be affected by the 

project, grouped in terms of the primary resources or districts to which they contribute. 

8.5 USE OF SECTION 4(f) RESOURCES 

Both the Transbay Terminal West Ramp Alternative (the Locally Preferred Alternative) and the 

Transbay Terminal Loop Ramp Alternative would require the demolition and removal of the 

Transbay Terminal (Figure 8.4-1 #1), an NRHP-eligible resource and contributory element to the 

San Francisco-Oakland Bay Bridge, a multi-component NRHP-listed property, and of its existing 

ramp and bridge approaches, which are also contributing elements to the Bay Bridge. 1

 

1 In accordance with California Public Resources Code Section 5027, the Transbay Terminal and terminal 

loop ramp, as NRHP-eligible structures that would be transferred from state (Caltrans) ownership to another public 

agency (the Transbay Joint Powers Authority) may not be demolished without the prior approval of the California 

Legislature. The California Legislature has considered the importance of proceeding with the Transbay Transit 

Terminal project and has granted a specific exemption to State Law prohibiting the demolition of historic structures 

with the following language: "the Legislature hereby approves demolition of the Transbay Terminal building at First 

and Mission Streets in the City and County of San Francisco, including its associated ramps, for construction of a 

new terminal at the same location, designed to serve Caltrain in addition to local, regional, and intercity bus lines, 

and designed to accommodate high-speed passenger rail service.” (AB 812, 2003) 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-13

Table 8.4-1: Section 4(f) Properties That Would be Used by the Transbay Terminal and 

Caltrain Downtown Extension Component Alternatives

Use Property Descriptor NRHP Status Cut-and-Cover Trench Stacked Drift Tunneling [1] 

San Francisco-Oakland Bay Bridge, a multi-component property listed on the NRHP

 Transbay Terminal, 

 425 Mission Street 

Individually 

eligible & 

contributor 

Demolition Demolition 

 Bay Bridge Approaches Contributor Demolition Demolition 

 Bus Ramps Contributor Demolition Demolition 

Second and Howard Streets District2

 165-173 Second Street Contributor Demolition Demolition 

 191 Second Street Contributor Demolition Demolition 

 580-586 Howard Street Contributor Demolition Demolition 

 163 Second Street Contributor 

Adverse effect due to loss 

of nearby contributing 

building 

Adverse effect due to loss of 

nearby contributing building 

 577-79 Howard Street Contributor Isolated from District Isolated from District 

 583-87 Howard Street Contributor Isolated from District Isolated from District 

 589-591 Howard Street Contributor Isolated from District Isolated from District 

Entire District Second and 

Howard Street District Eligible Use of District Use of District 

Rincon Point/South Beach Industrial Warehouse District

 35 Stanford Street Contributor Demolition No use 

 640 Second Street Contributor Demolition No use 

 650 Second Street Contributor Demolition No use

 670-680 Second Street Contributor Demolition No use

 301-327 Brannan Street Contributor Demolition No use

 130 Townsend Street Contributor Demolition No use

 136 Townsend Street Contributor Demolition No use

 144-46 Townsend Street Contributor Demolition No use

 148-54 Townsend Street Contributor Demolition No use

 162-164 Townsend Street Contributor Demolition No use

 166-78 Townsend Street Contributor

Construction Easement/ 

Temporary Occupancy/ 

No use

Construction Easement/ 

Temporary Occupancy/ 

No use

Entire Rincon Point/South 

Beach Industrial Warehouse 

District 

Eligible Use of District No Use of District 

[1] The tunneling option has been identified as the Caltrain Extension component of the Locally Preferred Alternative 

(LPA). 

 

2 The buildings at 577-79 Howard Street and 583-87 Howard Street are outside the APE but are contributing elements to 

the National Register District.
CHAPTER 8: FINAL 4(f) EVALUATION 

8-14 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

The Tunneling Option (identified for the Caltrain Extension component of the Locally Preferred 

Alternative) would require the removal of three historic buildings (Figure 8.4-1 #5) and result in the 

isolation from the remainder of the district of three other buildings (Figure 8.4.1 #6), all of which 

are contributors to the Second and Howard Historic District. These impacts would result in a use of 

these individual buildings and the District under Section 4(f). Under this tunneling option, the 10 

buildings that are contributors to the Rincon Point / South Beach District would be retained and 

would be underpinned to protect them from harm during construction. There would thus be no use 

of these properties or the District with this construction option. The stacked drift tunneling method 

has an extremely low likelihood of collapse or tunnel failure. Reducing impacts to historic 

properties was a primary factor in the identification of the tunneling option for the Townsend Street 

to Folsom Street segment of the Caltrain Extension component of the Locally Preferred Alternative.

A construction easement through an eighteenth property (affecting the southeast corner of the 166-

178 Townsend property, Figure 8.4-2 #3) would also be required to construct the subway for the 

Caltrain Downtown Extension under either construction option. The California Electric Light 

Company building would not be removed and would be underpinned to protect it from harm during 

construction. The easement would not constitute use under Section 4(f) pursuant to 23 CFR 771.135 

(7). The occupancy of land from the affected Section 4(f) property would be temporary, and less 

than the time needed for construction of the project. The encroachment would be for a construction 

easement only; there would be no change in ownership of the land. The scope of the work would be 

minor and there would be no changes to the nature or magnitude of the Section 4(f) resource; the 

building would be unchanged. Not only would there be no adverse physical impact, but there would 

be no interference with the purposes of the Section 4(f) resource, which would remain in place 

during construction. The resource would remain a contributor to its historic district. Following 

construction of the tunnel, the property would be returned to its original condition. 

The demolitions of the Transbay Terminal and ramp structures, demolition of three historic 

buildings that are contributors to a historic district, and isolation of three other buildings from the 

remainder of the district that would occur under the Locally Preferred Alternative would constitute 

a use of these historic buildings and the Second and Howard District under Section 4(f). The 

construction easement required for the building at 166-178 Townsend will not result in a use under 

Section 4(f). 

8.6 AVOIDANCE ALTERNATIVES 

Two alternatives were evaluated for each project component to achieve the project purpose and 

need. Also, the Caltrain Extension component has two construction Options. There are differences 

in effects on Section 4(f)-protected resources among these Alternatives and Options, as discussed in 

the following section, which is organized by project component. The No-Project Alternative is also 

briefly discussed. 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-15

8.6.1 TRANSBAY TERMINAL COMPONENT

There are no Transbay Terminal alternatives that are either reasonable, or feasible and prudent, and 

that avoid Section 4(f)-protected resources, as shown in the following paragraphs. 

8.6.1.1 Transbay Terminal Alternatives Considered in the Present Document 

The purpose and need for the Project includes the extension of Caltrain to the site of the existing 

Transbay Terminal in the Financial/South of Market downtown area (as required by Proposition H), 

as well as the ability to accommodate a California high-speed system (as also required by 

Proposition H). This Project’s purpose and need could not be achieved by rehabilitation of the 

present Transbay Terminal. 

Bringing the Caltrain/high speed rail tracks into the upper levels of the present terminal would 

displace portion of the current AC Transit operations, would require retrofitting the terminal, 

(substantially reducing its ability to function effectively), and would disrupt current transit 

operations. It would also require new elevated train tracks leading to the terminal, thus reducing 

the ability of redevelopment planning efforts to revitalize the area around the terminal. 

Additionally, such retrofit would require bringing the remainder of the present facility up to building 

codes and ADA requirements, adding additional cost and disruption to the present terminal 

operation; and terminal retrofit would require continued use of the eastern bus ramp (which would 

not occur under the selected Locally Preferred Alternative West Ramp Alternative), thus reducing 

the ability of the proposed redevelopment planning to revitalize the area surrounding the terminal. 

Bringing the Caltrain extension and high speed rail tracks into the basement of the present terminal 

is not practicable. 

Finally, it should be noted that the Metropolitan Transportation Commission’s Transbay Terminal 

Study generated a regional consensus among the participating agencies (Caltrans, AC Transit, 

Golden Gate Transit District, Muni, the City and County of San Francisco, the Peninsula Corridor 

Joint Power Board, and SamTrans) for a new terminal on the site of the current Transbay Terminal. 

To meet the purpose and need of the Project, it would be necessary to demolish the existing 

Transbay Terminal and the terminal loop ramp, both of which are Section 4(f)-protected resources. 

8.6.1.2 Transbay Terminal at Main/Beale 

The New Bus Terminal at the Main/Beale Site that was considered in the 1997 Draft EIS/EIR for the 

Caltrain Downtown Extension would not have constructed a new terminal at the site of the present 

Transbay Terminal but it would not have avoided removal of the existing Transbay Terminal and 

terminal loop ramp. Although this option would have placed bus operations at the Main/Beale site, 

the Caltrain Downtown Extension was still proposed to terminate underground at the site of the 

present Transbay Terminal, which required demolition and removal of the terminal and terminal 

loop ramp. Note that this bus terminal alternative had been endorsed by the San Francisco Board of 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-16 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

Supervisors but was ultimately found not to be feasible because the Main/Beale site could not 

provide for the needed level of AC Transit service. Withdrawal of the Main/Beale site was also 

consistent with the provisions of Proposition H (passed by the voters of San Francisco in November, 

1998), which called for a multi-modal facility on the site of the current Transbay Terminal. 

8.6.2 CALTRAIN DOWNTOWN EXTENSION COMPONENT

Two Alternatives with different horizontal and vertical alignment geometrics and two construction 

approaches (cut-and-cover trenching and tunneling) were evaluated to meet the project purpose and 

need for the Caltrain Downtown Extension. There would be no difference in effects to Section 4(f)-

protected resources between the Second–to-Mission Street and Second-to-Main Street Alternatives if 

constructed using the cut-and-cover trenching technique, however, construction of these alternatives 

using the Tunneling Option would affect fewer Section 4(f) protected properties, as discussed in the 

following paragraphs. There was no feasible and prudent Caltrain Downtown Extension Alternative 

that would avoid all historic properties. 

8.6.2.1 Cut-and-Cover Tunneling Option 

The Cut-and-Cover Option would require the removal of all 13 historic buildings described in 

Section 8.4, Potentially Affected Section 4(f) Properties. Ten of these buildings are contributors to 

the Rincon Point / South Beach Industrial Warehouse District and three are contributors to the 

Second and Howard Historic District. Removal of ten buildings from the Rincon Point / South Beach 

Industrial Warehouse District would result in a use of that district under Section 4(f) Removal of 

the three contributors to the Second and Howard Historic District would result in a use of the 

Second and Howard District through isolation of three other buildings from the remainder of the 

district. The Cut-and-Cover Option would also require a construction easement through the 

southeast corner of the 166-178 Townsend property, which is a contributor to the Rincon Point 

historic district; this easement would be temporary and would not require alteration or demolition of 

the building, and therefore would not constitute a use of the property. 

8.6.2.2 Stacked Drift Tunneling Option 

The Tunneling Option would avoid removal of 10 historic buildings that are contributors to the 

Rincon Point / South Beach Industrial Warehouse District, but would require removal of three 

buildings that are contributors to the Second and Howard Historic District, resulting in a use of those 

buildings under Section 4(f). Removal of these three buildings would also result in the isolation of 

three other buildings from the remainder of the district, resulting in a use of that District. The 

Tunneling Option constitutes an avoidance alternative for the 10 historic buildings that are 

contributors to the Rincon Point District. Reducing impacts to historic buildings and districts 

consistent with the requirements of Section 4(f) was a primary factor in the identification of the 

Tunneling Option for the Caltrain Downtown Extension component of the Locally Preferred 

Alternative. 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-17

The inability to successfully tunnel under the three historic structures in the Second and Howard 

District is due to ground conditions and the necessary Project facilities for this immediate area. A 

large number of closely spaced tracks are required for the segment leading from Folsom Street into 

the new Terminal. This is the areas where the tracks leading north on Second Street would need to 

brand into six tracks leading into the basement of the terminal. Soils near Second and Howard 

Streets are exceptionally soft and weak, and the excavations required for the multiple, closely 

spaced tracks would be wide. While it may be technically feasible to construct a single tunnel or 

perhaps twin bores under a given building, it is not considered practicable in the soft soils to open 

so many tunnels so close to each to accommodate the multiple tracks. 

The Tunneling Option would also require the same construction easement through the southeast 

corner of the 166-178 Townsend property, which is a contributor to the Rincon Point historic 

district, but this easement would be temporary and would not require alteration or demolition of the 

building, and therefore would not constitute a use of the property.

8.6.2.3 Caltrain Downtown Extension – Essex Street Stub-End Alignment Alternative 

In response to the curve radii problems associated with the 1997 Caltrain Downtown Extension 

alignment, an alternate subway alignment was reviewed that did not curve into the basement of the 

proposed new Transbay Terminal, but included a train terminal oriented perpendicular to and west of 

the existing Terminal. Therefore, it did not require demolition of the existing Transbay Terminal. 

Also, it would have been possible to construct this alignment using the stacked drift technique. This 

would have avoided demolition of all of the historic buildings in and around the Rincon Point / 

South Beach Industrial Warehouse District, while the alignment would not have encroached into the 

Second and Howard Historic District. 

This alternative was included in the Notice of Preparation and Notice of Intent to Prepare this 

EIS/EIR, but was found not to be feasible. During the scoping process, the public noted several 

shortcomings of this alignment, and these public comments and shortcomings contributed to the 

withdrawal of this alternative alignment from further consideration. Because the train platforms 

would not have been directly under the new multi-modal transit facility, internal passenger 

circulation and transfers between modes would have been substantially compromised. Also, the 

stub-end orientation meant that trains would not be able to enter one end of the station and exit at the 

other. In the stub-end configuration, trains would pull into the station and would need to reverse 

direction to exit. This would substantially impair operating efficiency and would not meet the project 

purpose to improve Caltrain service to downtown San Francisco. 

While it would have been possible to construct the Essex Street Stub-End Alignment of the Caltrain 

Downtown Extension without demolishing and erecting a new Transbay Terminal, this action would 

not have been a reasonable undertaking. Leaving the existing Transbay Terminal in place would 

have done nothing to improve space utilization, passenger circulation, signage, safety or operating 

efficiency within the existing Transbay Terminal. There would have been very limited potential for 

revenue-generating joint development within the terminal or its environs. The existing terminal 

footprint includes numerous structures crossing city streets, a condition that has contributed to the 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-18 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

continued deterioration and underutilization of land in the surrounding area. None of these 

conditions would have been improved without demolition of the terminal under this alternative. 

In summary, therefore, this alternative alignment was found not to be feasible or reasonable and it 

was withdrawn from further consideration. It therefore does not constitute an avoidance alternative 

under Section 4(f). 

8.6.3 NO-PROJECT ALTERNATIVE

The No-Project Alternative would not use the Transbay Terminal or the existing loop ramp

approach structures, but this alternative would not address the Project’s purpose and need. Note, 

however, that Caltrans is currently completing seismic retrofit of the loop ramp, and Caltrans’ plans 

include demolition and removal of the east ramps and reconstruction of the west ramps. Further, the 

existing Transbay Terminal building also requires substantial and costly retrofit and reconstruction 

to meet current seismic and other building codes. Interim retrofit measures have been taken, but the 

full reconstruction (to be undertaken by others) may be so extensive as to result in the use of the 

resource under Section 4(f). Given the high costs of retrofitting the existing terminal, the City of 

San Francisco requested Caltrans cooperation in considering replacement alternatives that would 

meet the project purposes identified for the present study. 

8.6.4 OTHER ALTERNATIVES

Other alternatives and alignment variations considered for the 1997 Draft EIS/EIR for the Caltrain 

Downtown Extension were not feasible or prudent for the present study. Geometrics for these 

alignment alternatives did not meet curve radius minimums required to accommodate high-speed 

steel-wheel-on-rail equipment currently in use in Europe and under consideration by the California 

High-Speed Rail Authority for implementation in California, including a station in downtown San 

Francisco. Constructing a new Caltrain alignment that precluded future use by high-speed rail 

equipment was not prudent, and these alternatives were withdrawn from further consideration. 

Figures 2.2-1, 2.2-5 through 2.2-7, and 2.2-9 though 21 show the project alternatives. Figure 2.3-1 

shows all of the alternatives for the terminal and extension components that were considered in the 

present study and the 1997 Draft EIS/EIR but found not to be viable. 

8.7 MEASURES TO MINIMIZE HARM 

There are no remaining feasible and prudent alternatives that avoid Section 4(f)-protected properties. 

The Locally Preferred Alternative comprising the Transbay Terminal West Ramp, Caltrain 

Downtown Extension with Tunneling Option for the Townsend Street to Folsom Street segment / 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-19

Second-to-Main Alignment Alternative and Full Build Development Scenario would include all 

possible planning to minimize harm to the properties. 

Measures to minimize harm are included in a Memorandum of Agreement (MOA). Signatory parties 

to the MOA include FTA and SHPO. The City and County of San Francisco, the Transbay Terminal 

Joint Powers Authority (TJPA), the Peninsula Corridor Joint Powers Board (JPB), and Caltrans 

are invited concurring parties to the MOA. The MOA is included in Appendix G of this Final 

EIS/EIR. The Measures are summarized below. 

1. Professional Standards: All activities regarding history, historic preservation, historical 

archaeology and prehistoric archaeology that are carried out will be carried out by or under 

the direct supervision of persons meeting, at a minimum, the Secretary of the Interior’s 

professional qualifications standards (48 FR 44738-9) in these disciplines. 

2. Mitigation of Effects on Components of the San Francisco-Oakland Bay Bridge 

(Bay Bridge) 

A. Permanent Interpretive Exhibit at the Terminal: TJPA will direct the design and 

engineering team for the Undertaking to integrate into the design of the new terminal a 

dedicated space for a permanent interpretive exhibit. TJPA will also consult with the 

City of Oakland about its interest in having a similar interpretive exhibit in the East 

Bay. 

B. Salvage: TJPA, in consultation with the State Department of Transportation 

(Department), will identify elements of the existing Transbay Transit Terminal that are 

suitable for salvage and interpretive use in the exhibit in the new Terminal or in 

museums. 

C. Oakland Museum of California Exhibit: TJPA will consult with Department and the 

Oakland Museum about contributing to Department’s exhibit at the Oakland Museum 

relating to the history and engineering of the major historic state bridges of the San 

Francisco Bay Area. 

D. Documentation: TJPA will consult with the California SHPO to ensure that the 

Transbay Transit Terminal has been adequately recorded by past efforts. TJPA will 

ensure that these records are accepted by SHPO prior to demolition of the Transbay 

Transit Terminal. 

E. Reevaluation of the Bay Bridge by the TJPA will occur within 180 days after FTA 

determines that the Undertaking has been completed. 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-20 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

3. Mitigation of Effects on Second and Howard Streets Historic District and Protective 

Measures for Rincon Point/South Beach Historic Warehouse Industrial District 

A. Protective Measures: TJPA, in consultation with the owners of historic properties 

immediately adjoining the construction sites, will develop and implement measures to 

protect the contributing elements of the Second and Howard Streets Historic District 

and the Rincon Point/South Beach Historic Warehouse Industrial District from damage 

by any aspect of the Undertaking. 

 

B. HABS/HAER Documentation: TJPA will assure that the three historic properties in 

the Second and Howard District to be demolished will be recorded in accordance with 

HABS/HAER standards, as appropriate. 

C. Repair of Inadvertent Damage: TJPA will ensure that any damage to contributing 

elements of the Second and Howard Streets Historic District and the Rincon 

Point/South Beach Historic Warehouse Industrial District resulting from the 

Undertaking will be repaired in accordance with the Secretary of the Interior’s 

Standards for Rehabilitation. 

D. Reevaluation of the Second and Howard Streets Historic District by the TJPA will 

occur within 180 days after FTA determines that the Undertaking has been completed, 

4. As described in Chapter 5 of this Final EIS/EIR, directly relevant mitigation measures 

include: 

• Provision of signage during construction. 

• Installation of a level deck for cut-and-cover construction 

• Provision of efficient sidewalk design and maintenance. 

• Underpinning of existing buildings, where deemed necessary, to protect existing 

structures from potential damage that could result from excessive ground movements 

during construction. Other alternatives, in lieu of underpinning, involve strengthening 

of the rock between the building and the crown of the tunnel. Grouting in combination 

with inclined pin piles can be used not only to strengthen the rock but to make the rock 

mass over the tunnel act as a rigid beam, which would allow construction of the tunnels 

with no adverse effects on the buildings that are supported on shallow foundations over 

the tunnel. 

• Proper design and construction of pile supported foundations for structures to control 

potential settlement of the surface. 

• Upon completion of the construction phase, power wash and/or paint buildings with 

visible signs of dirt and debris from the construction site (given that permission is 

obtained from the property owner to gain access to and wash the property with no fee 

charged by the owner). 

• Limit or prohibit use of construction techniques that create high vibration levels. 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-21

• Restrict procedures that contractors can use in vibration sensitive areas. 

• Require vibration monitoring during vibration intensive activities. 

• Restrict the hours of vibration intensive activities such as pile driving to weekdays 

during daytime hours. 

• Investigate alternative construction methods and practices to reduce the impacts in 

coordination with the construction contractor if resident annoyance from vibration 

becomes a problem. 

• Include specific limits, practices and monitoring and reporting procedures for the use of 

controlled detonation. 

• Use high-resilience track fasteners or a resiliently supported tie system for the Caltrain 

downtown extension for areas projected to exceed vibration criteria. 

• Require the project contractors to ensure that construction crews working at night 

direct any artificial lighting onto the work site in order to minimize "spill over" light or 

glare effects on adjacent areas. 

• Ensure that any damage to contributing elements of the Second and Howard Streets 

Historic District and the Rincon Point/South Beach Historic Warehouse Industrial 

District resulting from the Undertaking will be repaired in accordance with the 

Secretary of the Interior’s Standards for Rehabilitation. 

8.8 COORDINATION WITH DEPARTMENT OF INTERIOR 

The United States Department of Interior (DOI) provided the following comments regarding 

Section 4(f) matters related to the proposed Project in a letter from Willie R. Taylor, Director, 

Office of Environmental Policy and Compliance, Office of the Secretary, DOI, to Leslie Rogers, 

Region IX Administrator, FTA. (The DOI letter dated March 9, 2004 is contained in Appendix D.) 

The DOI comments and responses to those comments are provided in Table 8.8-1. 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-22 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

Table 8.8-1: Responses to the Department of Interior (National Park Service) Comments 

Department of Interior Comment Response to Comment 

Based on the information provided in the 

EIS/Report, it is apparent that no public 

parkland, refuge, or similar site would be 

affected by either of the action alternatives. 

Therefore, there are no Section 4(f) 

considerations with regard to recreational 

sites. 

Section 4.4 of this Final EIS/EIR, Volume I 

shows that there would be no impacts to public 

parklands, refuges, or similar sites. 

The National Park Service’s Pacific West 

Regional Office has reviewed this 

administrative draft document identifying and 

analyzing a “no action” alternative as well as 

“action” alternatives for individual 

components of the proposed project. A locally 

preferred Stacked Drift Tunneling West Ramp 

alternative is also deemed to be the 

environmentally superior alternative. 

The DOI reviewed the administrative draft Final 

EIS/EIR that identified the Locally Preferred 

Alternative (LPA) as the Stacked Drift Tunneling 

West Ramp alternative. This LPA is described in 

Section 2.2 of this Final EIS/EIR, Volume I. 

In regard to cultural resources, each of the 

“action” alternatives entails demolition of 

historic buildings. The locally preferred 

alternative would have significantly less 

impact on other listed historic structures in 

comparison with the Cut and Cover 

Trench/West Ramp alternative. 

As described in Sections 5.14 and 8.6.2 of this 

Final EIS/EIR, Volume I, the LPA would have 

significantly less impact on listed historic 

structures. 

Several options were withdrawn from full 

analysis because they would fall short of 

meeting the expressed purpose and need for 

action. None of the withdrawn options offered 

a feasible and prudent alternative for avoiding 

the identified effects on cultural resources. 

Alternative considered and withdrawn from 

consideration and reasons for their withdrawal 

are described in Sections 2.3 and Section 8.6 of 

this Final EIS/EIR, Volume I. 

The locally preferred Stacked Drift alternative 

slates six historic structures for demolition. 

Three of the resources slated for demolition – 

Transbay Terminal (425 Mission Street), Bay 

Bridge Approaches, and Bus Ramps – have been 

designated contributing resources to the San 

Francisco-Oakland Bay Bridge, a multiThese impacts associated with the LPA are 

described in Sections 5.14, 8.5 and 8.6 of this 

Final EIS/EIR, Volume I. The MOA for this 

Project is contained in Appendix G of this Final 

EIS/EIR, Volume I. 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-23

Table 8.8-1: Responses to the Department of Interior (National Park Service) Comments 

Department of Interior Comment Response to Comment 

component property listed on the National 

Register of Historic Places (NRHP). According 

to the draft Memorandum of Agreement (MOA) 

included in the EIS/Report, the California 

Legislature has granted a specific exemption to 

State law prohibiting the demolition of historic 

structures as follows: 

“The Legislature thereby approves demolition of 

the Transbay Terminal building at First & 

Mission Streets in the City and County of San 

Francisco, including the associated ramps, for 

construction of a new terminal at the same 

location...” (AB 812, 2003). 

Our concerns are twofold. First, three of the 

structures slated for demolition (and not 

addressed by AB 812) – 165-173 Second Street, 

191 Second Street, 580-586 Howard Street – 

have been designated as contributing resources 

in the Second & Howard Streets District. 

Demolition of these three structures in the 

Second & Howard Streets District also result in 

isolation of four additional contributing 

resources in the District, adding to the adverse 

impact of the undertaking on the integrity of the 

District. While it is clear that the proposed 

undertaking will adversely affect all six 

properties, not enough information has been 

provided in the EIS/Report materials to 

determine the overall effect of the proposed 

demolition on the integrity of the Second & 

Howard Streets District or the Bay Bridge 

District (as listed on the NRHP). 

Second, the MOA Section III (F) stipulates that a 

reevaluation of the Bay Bridge District shall 

occur within 180 days of completion of the 

undertaking to determine whether the 

nomination should be amended or whether the 

bridge no longer qualifies for listing and should 

In response to DOI’s request, the MOA 

(Appendix G) now includes a reevaluation clause 

not only for the Bay Bridge (MOA, Section III.E) 

but also for the Second and Howard Street 

District (MOA, Section IV.D.). Additional 

information has been added to Section 5.14 of 

the administrative draft Final EIS/EIR (shown as 

underlined and italics on pages 5-90, 5-91, 

5-103, and 5-104 of this Final EIS/EIR) stating 

that it is not anticipated that the Undertaking 

would result in a delisting from the NRHP of the 

remaining elements for either of these resources. 

Underlying reasons are provided. 

The number of isolated buildings shown in the 

administrative draft Final EIS/EIR (as reviewed 

by the DOI) has been changed from four to three 

for this Final EIS/EIR. Specifically, 163 Second 

Street would not be isolated but rather would be 

adversely affected due to loss of a nearby 

contributing building. 
CHAPTER 8: FINAL 4(f) EVALUATION 

8-24 Transbay Terminal / Caltrain Downtown Extension /Redevelopment Project EIS/EIR

Table 8.8-1: Responses to the Department of Interior (National Park Service) Comments 

Department of Interior Comment Response to Comment 

be removed from the NRHP. The MOA states 

that the Transbay Joint Powers Administration 

will conduct the evaluation in consultation with 

the SHPO. A similar clause is not included for 

the Second & Howard Street Historic District in 

the Mitigation Section IV of the MOA. From the 

information provided, it is unclear whether an 

evaluation was completed to assess the potential 

impact of the proposed undertaking on the 

Second & Howard Street Historic District, or if 

not, what was the basis for this result. If an 

evaluation has not been done, our 

recommendation would be to complete this 

process for the Second & Howard Street 

District. 

The Department of the Interior has no objection 

to Section 4(f) approval of this project, provided 

the measures to minimize harm mentioned above 

are included in the project plans and 

implementation. 

Because this Department has a continuing 

interest in this project, we are willing to 

cooperate and coordinate with you on a 

technical assistance basis in further project 

evaluation and assessment. 

As shown above, the requested measures to 

minimize harm in the DOI letter are included in 

the Project plans and implementation. Given 

DOI’s letter stating no objection with these 

measures in place, FTA has determined that 

there is no feasible and prudent alternative to 

the use of land from the national register 

properties required for the LPA and that 

implementation of the proposed LPA includes all 

possible planning to minimize harm resulting 

from such use (see Section 8.9 below). 

8.9 SECTION 4(f) FINDING 

It is determined that there is no feasible and prudent alternative to the use of land from the national 

register properties required for the Locally Preferred Alternative (LPA) and that implementation of 

the proposed LPA includes all possible planning to minimize harm resulting from such use. 

Underlying reasons for these findings include: 
 CHAPTER 8: FINAL 4(f) EVALUATION 

Transbay Terminal / Caltrain Downtown Extension / Redevelopment Project EIS/EIR 8-25

• The regional designation of the Transbay Terminal site as the appropriate site for a new 

regional multi-modal terminal, 

• The requirement for and advantages of providing new bus ramps to the new terminal 

(i.e., elimination of the east loop, stacking of the west ramps), 

• The need to provide commuter and high-speed train service into the basement of this 

new facility to enhance regional transit connectivity, 

• The major advantages (i.e., reduced community impacts and project costs) of using 

public rights-of-way (Townsend and Second Streets) for the underground train 

extension, and the minimum curve radii required for high speed trains, 

• The soft ground conditions and multiple, closely-spaced tunnel requirements in the 

Second and Howard Streets area, 

• The selection of a Locally Preferred alternative minimizing the number of 4(f) resources 

used, and 

• The agreement to document and preserve elements of the 4(f) resources via recordation, 

displays in the new terminal and at local museums, financial participation in the 

production in educational videos, and the salvage of appropriate elements in the 

terminal.